keeping your information protected
Welcome to Willow Wellness. We honour your privacy and are committed to protecting your personal information. This Privacy information outlines key ways that we collect, use, disclose and safeguard your personal information when you use our services or visit our website.
In order to provide services in a safe manner, we collect information from you to benefit your overall holistic health and wellness care. This policy covers our team – of Registered Massage Therapists, Osteopathic Manual Practitioners, Social Workers and Psychotherapists, Physiotherapists, Reflexologists, Yoga Therapists, Breathwork Coaches, Yoga and Movement Instructors, Aestheticians and all who work with us – who collect specific personal information in order to provide services to you. Under the Personal Health Information Protection Act (PHIPA), rules for the collection, use and disclosure of personal health information are outlined. Under this Act, it outlines some of the pertinent items below:
WHAT IS PERSONAL INFORMATION?
“Personal information” is information about an identifiable individual. Personal information includes, but is not limited to, information that relates to:
- an individual’s personal characteristics (e.g., gender, age, home address, telephone number, family status);
- health (e.g., health history, health conditions, health care received by them);
- activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual).
Personal information is different from business information (e.g., an individual’s business address and telephone number). Generally speaking, business information is not protected by privacy legislation in Canada.
WHAT PERSONAL INFORMATION WE COLLECT
Willow Wellness collects personal information from you directly when you interact with our website, request and use our goods and services, complete a client survey, and otherwise communicate with us, including with one of our health care and wellness professionals. The personal information we collect may include, but is not limited to, the following:
- Contact information, such as your name, email address, phone number, and mailing address;
- Health information such as your health history, individual’s family health history, information about the individual’s physical condition and physical function;
- Demographic information, such as your age, gender, and occupation;
- Billing information, such as your credit card number, ccv, expiry date, and billing address;
- Information we generate about you, including the observations or opinions of our health care professionals and information relating to your use of our goods or services;
- Account registration information, such as your username and/or email address, password, and password hints and security questions;
- Device and connection information, such as cookies and other tracking information, Internet Protocol (“IP”) addresses, browser type, language, domain name, referral data, and website or other platform access times;
- Information relevant to job applications, such as work and education history, specialized knowledge, and any other information provided as part of the application process, and
- Any other personal information for which we may obtain your consent from time to time.
When we provide services to youth, we collect, use and disclose personal information for children under 14 with permission of a parent or guardian. We do follow all relevant legislation to also honour privacy, consent and safety of minors.
HOW WE USE PERSONAL INFORMATION
Willow Wellness collects, uses and discloses personal information for the primary purpose of providing treatment. For example, we may collect information about your health history, including family health history, physical condition, physical function and social situation in order to help us assess your health needs, to advise you of your options and then to provide the care you choose to have. Related to this purpose, we collect a baseline of health and social information so that in providing ongoing health services, we can identify changes that occur over time.
We also collect, use and disclose personal information for a variety of business purposes, including:
- Billing: Invoicing clients for goods or services, processing credit card payments, and collecting unpaid accounts;
- Customer service and ongoing communication: Responding to questions, complaints, comments and feedback; communicating with you about appointments or appointment history, and reminding you to book follow-up services; and, with your consent, communicating with you about new products, services, events or promotions that you may be interested in;
- Personalized recommendations and targeted advertising : Personalizing the goods or services we recommend so that they are tailored to your interests and needs; and identifying patterns of behaviour to offer relevant suggestions and provide a personalized online experience, including through the delivery of targeted advertising and marketing services which may be directed to you via third party sites and on social media platforms;
- Account management: Providing secure access to your account;
- Business improvement: Assessing trends to help develop, evaluate, and improve our goods, services, and website, and otherwise improving our business operations;
- Purposes permitted or required by law: Detecting, preventing, or suppressing fraud or other prohibited or illegal activities; meeting our and our health care professionals’ legal and regulatory requirements; and
- Other purposes for which we may obtain consent from time to time and/or as otherwise described to you at the time of collection.
HOW WE SHARE PERSONAL INFORMATION
We may transfer personal information to third party service providers with whom we have a relationship and who assist us in providing our products and services. These third party service providers are acting on our behalf in respect of the personal information that we transfer to them. Some of these third parties may be located in jurisdictions outside of Canada, including the United States and the EU. The privacy laws applicable in other jurisdictions may differ from those in Canada.
We only transfer personal information that is reasonably necessary for the purposes intended. When transferring personal information to third party service providers, we employ reasonable contractual and/or other means to ensure those third parties provide a comparable level of protection to the personal information. The third parties are prohibited from using your personal information for unrelated purposes. Accountability for any personal information that is transferred to third party services providers remains with us. Our electronic platform, Mindbody has sound cybersecurity protection (aligns with CIS CSC 20 and NIST Cybersecurity frameworks) and Mindbody is HITRUST CSF and PCI DSS Level 1 service provider certified.
We may also disclose personal information to the associations, boards and/or provincial regulatory bodies (“regulatory authorities”) that oversee our health care professionals. Such disclosures would typically be for the purposes of standards audits, assisting in investigations or complying with an order issued by a regulatory authority. When personal information is disclosed to a regulatory authority, it will be subject to the privacy obligations and policies applicable to that particular regulatory authority.
We may also disclose your personal information as permitted or required by law. For example, we and our third party service providers may disclose your personal information to law enforcement, government bodies or other organizations in response to a warrant, subpoena, or other court order. Such disclosures may also be made for the purposes of investigating a breach of an agreement or contravention of law, for detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable law.
Finally, we may also disclose personal information to another organization in the event that:
- we buy, sell, or otherwise acquire or dispose of our organization or a part of our organization, or any of its assets;
- we merge or amalgamate our organization with another;
- we make or receive a loan or other financing;
- an organization creates a charge on, or the take of a security interest in or a security on, any assets or securities of our organization;
- we lease or licensing of any of an organization’s assets.
Any such disclosures will be conducted in accordance with applicable law.
HOW WE PROTECT AND RETAIN PERSONAL INFORMATION
Willow Wellness understands the importance of protecting personal information. For that reason, we take reasonable precautions to protect the personal information that we collect throughout its entire lifecycle.
We have implemented generally accepted standards of physical, administrative, and technical security measures to protect personal information against unauthorized collection, use, disclosure, loss, misuse, alteration or destruction. Only authorized Willow Wellness personnel and third-party service providers with a need to know the information are provided access to personal information, and these individuals are required to treat all personal information as confidential.
We retain personal information for as long as necessary to fulfil the purposes described above, or as may be permitted or required by law, including as may be required by our health care professionals’ regulatory authorities and standards of professional conduct. After that time, we delete or destroy personal information using secure methods.
Where granted by applicable law, you have the right to request access to the personal information that we have collected about you and to request that any inaccuracies in that information be corrected. You may also have the right to request that the personal information we have about you be deleted or de-indexed, in certain circumstances.
You also have the right to request that we cease processing your personal information at any time, subject to legal and contractual obligations and reasonable notice. If you request to “opt out” or withdraw your consent for the collection, use and/or disclosure of your personal information, we may inform you of the consequences of doing so before processing your request.
To exercise any of the above-mentioned rights, please contact us using the contact information provided below.
In addition, you can opt-out of our marketing communications at any time by contacting us using the information provided below or using the “unsubscribe” mechanism included in the communication; however, you will continue to receive transactional messages from us, as may be relevant, and correspondence relating inquiries, comments, or complaints.
COOKIES AND TRACKING INFORMATION
To elaborate on the uses mentioned above, cookies may be used for targeted online advertising by Willow Wellness and third party merchants on third party websites. We may work with advertising companies that use their own tracking technologies (including cookies) on our websites in order to provide you with tailored advertisements on our behalf. These companies may collect information about your activity across your different devices on our website and on third party websites and apps, and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
THIRD PARTY WEBSITES
P.O. Box 670, 5944 Perth Street
Richmond, ON K0A 2Z0
For more information and complaints: Information and Privacy Commissioner/Ontario; 2 Bloor Street East, Suite 1400, Toronto Ontario, M4W 1A8
Tel: 1-800-387-0073 Fax: 416-325-9195
If you have a concern about any of our staff, we would ask you to discuss those concerns with us; however, if we cannot satisfy your concerns, you are entitled to complain to the applicable regulatory body:
COLLEGE OF SOCIAL WORKERS AND SOCIAL SERVICE WORKERS OF ONTARIO – 250 Bloor St. E., Toronto ON, M4W 1E6. 416-972-9882. [email protected]
COLLEGE OF REGISTERED PSYCHOTHERAPISTS OF ONTARIO – 375 University Ave, Suite 803, Toronto ON, M5G 2J5. 416-479-4330. [email protected]
COLLEGE OF MASSAGE THERAPISTS OF ONTARIO – 1867 Yonge Street, Suite 810
Toronto, ON M4S 1Y5. 416.489-2626. [email protected]
COLLEGE OF PHYSIOTHERAPISTS OF ONTARIO – 375 University Avenue, Suite 800, Toronto, ON M5G 2J5. 416-591-3828. [email protected]
REFLEXOLOGY ASSOCIATION OF CANADA – 165B Garry St. Winnipeg, MB R3C 1G7. (204) 477 4909. [email protected]